E.D. New York cuts fee award 30%, including for block billing

What happened

The fee applicant, represented by Milman Labuda Law Group PLLC, sought $151,259.69 in attorneys' fees as a contempt sanction. Judge Pamela K. Chen awarded $105,881.78, a reduction of $45,377.91, or 30%. The court applied a single 30% cut to the total hours, citing three reasons: billing for numerous entries unrelated to the defendants' alleged non-compliance as set out in the court's March 2025 memorandum and order, pervasive block billing in the invoices, and vague entries.

What the court said

a review of Sage's invoices shows numerous unrelated entries, as well as pervasive block-billing.

reducing attorneys' fees award for contempt sanction by 30% to account for inclusion of work unrelated to contempt motion, vague entries, and block-billing

The court also reduced the award for: unrelated claims.

Why it matters

The ruling shows that a court will reduce a fee award when time records mix work on unrelated claims with the sanctioned conduct, and when block billing and vague descriptions make it hard to separate compensable work. A single percentage cut can address several recordkeeping problems at once.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the E.D. New York approves and attorney fee motions in New York federal courts.

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.